Last updated: 24 November 2025
Over the course of 2025, product safety and regulatory reform developed rapidly in the UK. The Product Regulation and Metrology Act 2025 (PRAM) became law on 21 July 2025.
The purpose of the PRAM is to provide a broad framework, under which secondary legislation can be made for the purpose of reducing or mitigating risks presented by products, and/or ensuring they operate efficiently (see below). The devil will be in the detail and drafts of the proposed secondary legislation are not available yet. However, we have set out below a summary of the insights that the government has provided thus far regarding the legislative proposals. It will come as no surprise that reform concerning online marketplaces remains a key priority.
Product safety reform in the EU is much further advanced, with the General Product Safety Regulation (Regulation 2023/ 988) (“EU GPSR”) applying from 13 December 2024. The EU GPSR has applied in Northern Ireland (but not the rest of the UK) since then, given arrangements put in place following Brexit (see OPSS’s guidance).
What does the PRAM itself say?
The PRAM provides a broad framework of powers (e.g., to pass regulations related to the marketing or use of products in the UK for the purpose of reducing or mitigating risks presented by products, or ensuring that products operate efficiently or effectively). Those regulations could make provision about requirements that must be met in relation to products marketed or used in the UK or in order for products to be marketed or used in the UK (such as requirements in relation to the production, components, use or marking of products etc).
The PRAM also provides that regulations may make provisions about the enforcement of product regulations by, for example, doing the following:
(i) Conferring functions on an authority (likely OPSS) to monitor compliance, investigate suspected non-compliance, secure compliance or mitigate the effect of non-compliance with product regulations
(ii) Creating or widening the scope of criminal offences
(iii) Conferring power on an authority to impose civil sanctions (including fines)
The PRAM is now in force, as it became law on 21 July 2025.
What can we glean from the background briefing notes to the King’s Speech?
The background briefing notes to the King’s Speech, which was delivered on 17 July 2024, gave us the first indications of how the new Labour government intended to take forward the product safety reform started by the previous Conservative government.
The background briefing notes stated that the bill was intended to:
Ensure the UK is better placed to address modern day safety issues, harness opportunities that deliver economic growth, and ensure a level playing field between the high street and online marketplaces.
Based on the notes to the King’s Speech, the PRAM is intended to enable the government to mirror or diverge from updated EU rules “so that we can maintain high product safety while supporting businesses and economic growth”. The notes recognise the current divergence between rules in Northern Ireland and the rest of the UK following Brexit and the Windsor Framework, and points to powers in the PRAM that would allow the government to “make changes to GB legislation to manage divergence and take a UK-wide approach, where it is in our interests to do so”.
According to the background briefing notes, the PRAM is intended to address the following specific challenges:
- Enable the government and its regulators to tackle non-compliance and target interventions by allowing greater sharing of data between regulators and market surveillance authorities
- Enable the UK to keep pace with technological advances, such as AI, and address challenges such as the fire risk associated with e-bikes and lithium-ion batteries
- Identify new and emerging business models in the supply chain, and ensure the responsibilities of those involved in the supply of products, such as online marketplaces, are clear
- Ensure that the law can be updated to recognise new or updated EU product regulations (including CE marking, where appropriate) to prevent additional costs for businesses and provide regulatory stability
The background briefing notes also highlighted that there is an urgent need to legislate to respond to emerging threats to consumer safety (e.g., to address incidents arising from ingesting button batteries).
One priority area for the UK government following the introduction of the PRAM is to combat the sale of unsafe products through online marketplaces. The government is expected to introduce requirements for online marketplaces to do the following:
- Take reasonable steps to prevent non-compliant and unsafe products being made available on their platform
- Take reasonable steps to ensure that sellers operating on their platform comply with product safety obligations and to take action against sellers where necessary
- Provide consumers with appropriate guidance and information when purchasing products
- Cooperate with regulators and provide ongoing assurance, including through responding to requests and quickly removing known unsafe products from being made available
What did we learn from the government’s response to the Product Safety Review consultation?
On 5 November 2024, the government published its response to the Product Safety Review consultation, which was carried out in 2023.
The government listed the following short term key priorities for reform over the next year:
- Addressing the issues faced by the sale of unsafe goods through online marketplaces — for example, by introducing new specific requirements for online marketplaces to clarify and modernise their responsibilities, and building on best practices to create a “proportionate regulatory framework”, where online marketplaces would take steps such as providing consumers with appropriate information, instructions and warnings about the product prior to purchase
- Considering how new and emerging cross-cutting hazards are adequately addressed (e.g., the choking hazard presented by button batteries or the fire hazard presented by lithium-ion batteries)
- Monitoring immediate changes to the EU product and metrology legislation (e.g., relating to common charger solutions and measuring noise from outdoor equipment)
The government also remarked that, in the coming months, it will consider the most effective way to progress voluntary digital labelling.
The government recognised that these are complex reforms that will require further consultation with businesses, consumer groups and other interested parties.
What did we learn from the recent OPSS delivery report?
OPSS published its delivery report for 2024-2025 on 30 July 2025. The report makes for interesting reading, particularly given that the proposed reforms outlined above are likely to result in greater powers for OPSS.
The report indicates that OPSS is increasingly using its enforcement powers to improve product safety in the UK. We have listed some examples of OPSS’s actions below:
- In 2024/2025, targeting by OPSS’s Border Profiling Unit (working with HMRC) resulted in checks on consignments covering over 14 million goods at the border, with 2.63 million goods (19%) being refused entry to the UK (e.g., unsafe e-bikes, toys, cosmetics, baby products and electrical products).
- Published statistics in June 2025 showed that in 2024, there were 211 fires reported involving e-bikes and e-scooters in the UK, and eight fatalities. OPSS undertook a programme of targeted checks on a range of businesses selling e-bikes, e-scooters and products used to convert standard bikes to e-bikes, including both online sellers and those with a physical presence. Since 2022, enforcement activities have led to 21 product recalls and 29 product safety reports being published for unsafe or non-compliant e-bikes or e-scooters subject to corrective action.
- During the year, 1,418 product safety notifications were received and processed via the Product Safety Database (PSD), through which OPSS and other market surveillance authorities shared information on product safety concerns. The most frequently notified products for the 2024-25 year were electrical appliances and equipment (470), followed by toys (344) and cosmetics (213). The most notified harm types were fire (212), injuries (174) and electric shock (135).
- The most common corrective action reported was the import being rejected at the border, followed by destruction of the product and the removal of the product listing by the relevant online marketplace.
What does this mean for your business?
The UK product regulatory and safety landscape is continuing to evolve. Concrete developments are underway, and change is likely to gather pace now that the PRAM is in force.
Businesses in the UK should take every opportunity to engage with OPSS and the government on any specific proposals for reform that are relevant to them. It appears that OPSS and the government are keen to ensure that reform is effective and proportionate. Businesses are best placed to flag whether particular proposals are unfeasible or if there is a better way in practice of achieving the same goal.
While the government’s focus at the moment appears to predominantly be on the issues outlined above, it is likely that the government will also turn to consider changes to the strict product liability regime in the UK (particularly as the new EU Product Liability Directive (2024/2853) will apply from 9 December 2026).
